COMERICA INC — Director's Dealing 2005

Jan 5, 2005

SEC Form 4 — Statement of Changes in Beneficial Ownership

Issuer: COMERICA INC /NEW/ (CMA)
CIK: 0000028412
Period of Report: 2005-01-03

Reporting Person: FRIDHOLM ROGER (Director)

Non-Derivative Transactions

Date	Security	Code	Shares	Price	A/D	Holdings After	Ownership
2005-01-03	Common Stock	A	12	$60.63	Acquired	12061	Direct

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	200	Indirect
Common Stock	1000	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Director Stock Option (right to buy)	$19.92	2005-05-19	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$29.08	2006-05-17	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$40.09	2007-05-16	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$65.13	2008-05-15	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$62.75	2009-05-21	Common Stock (1500)	1500	Direct
Director Stock Option (right to buy)	$44.13	2010-05-19	Common Stock (2000)	2000	Direct
Director Stock Option (right to buy)	$57.15	2011-05-20	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$64.5	2012-05-21	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$43.63	2013-05-20	Common Stock (2500)	2500	Direct
Director Stock Option (right to buy)	$53.87	2014-05-18	Common Stock (2500)	2500	Direct
Restricted Stock Units	$0	1988-08-08	Common Stock (319)	319	Direct

Footnotes

F1: Includes stock units held pursuant to deferred director plans and shares purchased with reinvested dividends as of January 3, 2005.

F2: Each restricted stock unit represents a contingent right to receive one share of Comerica common stock.

F3: The restricted stock units vest one year after the date of grant. Vested shares are settled one year after the insider's date of retirement.